According to Provision 5.e.2, a downstream vendor must adhere to a documented system to manage environmental, health and safety risks and legal requirements. There are two parts to this requirement. First, it must be a “documented” (i.e. written) system. Second, the downstream vendor must “adhere” to the system. Having a downstream vendor simply answer a survey or state that they have an EH&S management system is not objective evidence of their adherence to it – and does not in itself meet the requirement.